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December 15, 2015

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition for Exemption Request under Section 333 of the FAA Modernization and Reform Act of 

2012

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Dr. Luis 

Daniel Otero. (Applicant), Associate Professor of Engineering Systems from the Florida Institute of 

Technology, seeks an exemption for the Federal Aviation Regulations (FARs) listed in this petition, for 

the safe operation of small Unmanned Aerial Systems (sUAS) in airspace regulated by the Federal 

Aviation Administration (FAA). These operations will be conducted with and under the conditions herein 

or as may be established by the FAA as required by Section 333. These limitations provide for at least an 

equivalent or even higher level of safety for sUAS operations.

The requested exemption would permit the applicant to pursue commercial interests primarily in 

research, to be conducted under the Director of the Transportation Systems Engineering Research 

(TSER) Lab at Florida Institute of Technology. All sUAS operations would support scientific research in 

aerial acquisitions, structural inspections, remote sensing and system development. 

The requested exemption would authorize the applicant to perform commercial operations that would 

provide the following benefits to the public:

 Commercial use of a sUAS for aerial acquisitions and structural inspection would be in direct 

support of university and private scientific research.

 Support of research would directly influence and improve the use of sUAS in various 

applications, including agriculture, natural resource monitoring, structural inspections and 

emergency services.

 The sUAS reduces safety concerns in areas where terrain or subject matter is inaccessible, 

inhospitable, hazardous and unsafe to enter or may cause undue injury or loss of life.

 The sUAS operates at low altitude (<400 ft AGL), providing high resolution imagery that cannot 

acquired be acquired by manned aircraft without compromising safety and adding to risk levels 

to life and property

Exemption is requested for the following regulations, 14 CFR Part 21, 14 CFR Part 91.203 (a) & (b), 14 

CFR Part 45.23 (b), 14 CFR Part 91.7 (a), 14 CFR Part 91.9 (b)(2) & (c), 14 CFR Part 61.113 (a) & (b), 14 

CFR Part 61.133 (a), 14 CFR Part 91.103, 14 CFR Part 91.109 (a), 14 CFR Part 119 (c), 14 CFR Part 121, 14 

CFR Part 151 (a), 14 CFR Part 405 (a), 14 CFR Part 407 (a)(1), 14 CFR Part 409 (a)(2) and 14 CFR Part 417 

(a).

Appendix A outlines the rules mentioned above and explains why exemptions to these regulations are 

appropriate to allow sUAS operation while observing equivalent or exceeded levels of safety and in 

consideration to the public interest.
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Statement of Background, Proposed Commercial Applications and Public Benefit

Systems engineering is a non-traditional engineering discipline that involves technical and managerial 

approaches to develop operable complex systems that meet requirements within various types of 

constraints. Systems engineering integrates various disciplines for the realization of systems, 

progressing through a series of phases, from initial concept to implementation and system 

retirement. This integrative engineering discipline adopts a systems thinking/approach to emphasize 

overall system performance instead of individual component performance. 

The focus of the TSER lab at Florida Tech is to implement systems engineering principles to develop 

practical solutions to complex problems associated with transportation systems. Researchers at the 

TSER lab are currently investigating ways to improve the effectiveness and costs associated with the 

inspection of key structural elements within transportation systems (e.g., highway bridges, railroad 

bridges, and high mast lighting posts). Their research efforts are expected to yield significant 

improvements in data gathering and analyses procedures employed to evaluate the structural health of

transportation infrastructure elements.

At the TSER lab, faculty and graduate students conduct research utilizing equipment such as aerial 

platforms and various types of sensors (e.g., mobile LiDAR, imaging and wireless sensors). By 

conducting cutting edge research using the latest in sensor technology and data analyses approaches, 

researchers at the TSER lab are dedicated to developing solutions of high impact to society.

If the proposed exemption is approved, the petitioner intends to acquire and provide structural imagery 

and data solutions in support of scientific research and monitoring for structural inspection applications. 

The petitioner also intends to use the sUAS to develop and test various imaging and remote sensing 

payloads for applications in structural inspections, agriculture, mapping and surveying, and other 

applications. All flights will be conducted with permission with the property owner or appropriate 

governing agency. All sUAS flights will be conducted by operators in minimum possession of an airman 

certificate with a U.S. driver’s license, issued by a state, the District of Columbia, Puerto Rico, a territory, 

a possession, or the Federal government. 

The application of UAS in these instances would produce valuable and sustainable data for the 

development of future products and applications. This development would provide definite results for 

improving the effectiveness and costs associated with the inspection of structural elements, especially in 

hard-to-reach areas, reducing the requirement of heavy machinery and the use of human personnel to 

climb large and tall structures. This removes human risk from current structural inspection methods.

The rotorcraft sUAS to be used for the proposed applications are as follows:

 DJI Phantom 2 Vision +

 DJI Inspire

The name and address of the applicant are:

Dr. Luis Daniel Otero

Telephone: 321-674-7173

Email: lotero@fit.edu
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Address: Department of Engineering Systems

Florida Institute of Technology

150 West University Boulevard

Melbourne, FL 32901

United States of America

Requirements and Qualifications for Approval under Section 333 of the Reform Act

The sUAS operations proposed in this petition for exemptions qualify for an expedited under Section 

333 of the Reform Act. This petition enumerates how each statutory criteria and other relevant factors 

are satisfied. The proposed operations would enable the use of sUAS under strictly controlled 

operational conditions. 

All Pilot in Command (PIC) and Visual Observer (VO) agree to follow the following guidelines regarding 

the sUAS, crew and flight operations of the TSER Lab. 

Unmanned Aerial Systems Guidelines

 The sUAS will always weigh less than 55 lbs. 

 The sUAS will operate at a maximum speed no greater than 25 knots. 

 The sUAS will operate at or below 400ft AGL. 

 The sUAS will be operated under visibility and cloud clearance requirements equivalent to Visual 

Flight Rules (VFR). 

 The sUAS will be operated within visual line of sight (VLOS) of the PIC and VO(s). 

 The sUAS shall not be operated within 5 miles of an airport without prior approval of, and 

establishing a line of communication for the duration of the flight operations with the 

controlling authority of that airspace/airport. 

 The sUAS will be equipped with an autopilot system in which the sUAS will utilize GPS 

navigation, systematic pre-flight checks, and failover safety mechanisms such as return-tohome, auto-land, loiter and flight abort safety features. 

Pilots, Visual Observer(s) and Ground Control Station crew Guidelines

 The minimum crew for each operation will always consist of the UAS Pilot in Command (PIC), 

Visual Observer (VO) and/or Ground Control Station (GCS) crew. 

 The sUAS pilot will be considered the Pilot in Command (PIC) and be responsible for conducting 

safe flight operations. The PIC will be trained for the safe operation of the sUAS. Training will 

include operations under normal and emergency conditions. This will include the familiarization 

of the flight manual and other publications available from the sUAS manufacturer and flight 

training which includes basic flight maneuvers, emergency procedures, navigational and 

situational awareness, loss of signal(s) and overall safety.

 PIC, VO(s) and/or GCS crew will have appropriate communications established in advance of any 

flight operations. 

 A briefing will be conducted in regard to the planned sUAS flights prior to each operation, with 

all personnel.
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Flight Operations Guidelines

 Written, and/or documented oral permission from property owners or land management 

agency will be obtained prior to an operation. 

 Risk assessment evaluation will be conducted for safe site operations and flight conditions 

before each mission. 

 Flight planning will include the area of operation which will be strictly defined, including the 

lateral and vertical areas where the sUAS will operate and flight completion with at least 20% 

battery power remaining.

 Appropriate safety procedures will be generated and followed for each area of operation.

 The UAS shall operate from a location directly next to the PIC and GCS crew. Non-essential 

personnel will be at an appropriate distance away or a minimum of 100ft from the operation.

Exemptions are made if barriers or structures are in place which may sufficiently protect nonparticipating persons in case of emergency. 

 See and avoid procedures will always be followed.

 sUAS operations will be conducted in class G airspace, whenever possible. If operation in other 

airspace is required, the appropriate controlling authority will be notified at least 24 hours prior 

to the operation and necessary authorizations will be acquired.

 Flight information must be relayed to the Ground Control Crew during operations through radio 

communication. Flight information relayed to the PIC will include altitude, speed, compass 

heading/bearing, aircraft angle of attack, flight time, battery power remaining, and other 

telemetry information. 

 Radio frequencies are unmodified from their factory settings at 2.4GHz and between 5.728 GHz 

and 5.85 GHz for the first person view system which are both compliant with Federal 

Communications Commissions (FCC).

 Flight paths and mission will be fully explained by the PIC prior to any flight including areas of 

interest to the pilot, area of take-off and landing, emergency landing procedures, and flight 

mission goals.

 Software level geofencing will be operational at all times, warning the operator of sUAS 

governed flight borders within a pre-determined radius and at an altitude at or under FAA 

governing distances and altitudes, including no-fly areas including but not limited to the 5 mile 

radius surrounding airfields. 

Proposed General Operations

 Areas of interest for flights include highway structures located above water where sUAS 

operations will take place under the highway structures not at or above normal pedestrian 

occupancy level (ie. Under a bridge structure over water).

 Flights will be conducted within visual line of sight by the PIC and VO at all times. Take-off and 

landing will be done at pre-designated location at a minimum distance of 100ft or at a location 

separated by a body of water from all persons. 

 Pre-flight checks will be performed by both the PIC and VO prior to any take-off procedures 

prior to engaging the sUAS. Pre-flight checks include but are not limited to a check of the onhand first aid kit and components, a visual check of all system components for any unusual signs 
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of wear, hands on check for loose wires or other sUAS components, and a hands on check of 

sUAV motors and propellers. 

 Prior to take-off a verbal communitive warning alarm will be sounded confirming all parties 

involved are aware of the arming and engaging of the motors and consequently the sUAS; 

landing procedures will be conducted similarly and at a safe distance away from all persons 

involved or otherwise in the sUAS mission. 

HML Inspection Operations

 In the case of a High Mast Luminary (HML) inspections with the proposed UAVs, standard 

Florida Department of Transportation (FDOT) safety and Maintenance of Traffic (MOT) 

procedures will be followed. UAV operations will be limited to flying the height of the pole +/-

15ft on the north, south, east, and west faces of the pole to acquire 100% coverage of both the 

supporting structure and luminary. 

Inspection of Highway Bridges

 Proposed bridge inspections with the listed UAVs are limited to underside bridge inspections 

when the bridge is over a culvert, waterway, or otherwise unpopulated scene, up to bridge deck 

height. After pre-flight checks have been performed the UAV is to be launched off of a cleared 

pile cap within VLOS and will be maneuvered to capture information of the bridge substructure

at the predesignated safe distance from all parties. Bridge structure information will be

gathered in sections designated by adjacent piers to ensure constant UAV VLOS.

Inspection of Railway Bridges

 Proposed Railway Bridge inspection with the listed UAVs are in line to follow the strict safety 

guidelines of the Rail owners. The pilot and members involved with the flight who are present at 

the time of inspection will be trained on the railways rules and regulation by proof of their 

ownership of the appropriate safety training card. The designated person in charge will brief the 

UAV team before each inspection, following the railways standard proceedings, at which time 

the audible alarms, clearance distances, and inspection flight plan overview will be addressed 

for that particular railroad bridge. During UAV flight, all onsite personnel will follow the standard 

operating procedures set forth by the UAV team regarding safe operating distances to 

personnel. 

The applicant requests that the publication and comment procedures be waived in accordance with 14 

CFR § 11.87 which states:

“§ 11.87 Are there circumstances in which FAA may decide not to publish a summary of my 

petition for exemption?

The FAA may not publish a summary of your petition for exemption and request comments if 

you present or we find good cause why we should not delay action on your petition. The factors 

we consider in deciding not to request comment include: 

(a) Whether granting your petition would set a precedent 
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(b) Whether the relief requested is identical to exemptions granted previously. 

(c) Whether our delaying action on your petition would affect you adversely. 

(d) Whether you filed your petition in a timely manner.

The applicant has good cause to request the FAA to waive the comment period and not delay action on 

the petition because:

(a) The applicant would not set any precedent. Exemptions numbers 12353, 12583, 13074, 13212 

and 13302 are all granted petitions to allow operations of sUAS for structural inspections of 

various infrastructure such as bridges, pipelines and towers and aerial photography and 

surveying.

(b) This petition for exemption is requesting relief identical to the above mentioned petitioners. The 

regulations that the applicant is seeking relief from were chose directing from the FAA’s chart in 

“Section 333 Guidance”. This was done so that the FAA may waive the comment period and 

rapidly grant this petition. Furthermore, most contents of this position is adapted and similar 

from previously approved exemptions.

(c) Delaying the granting of this petition would adversely affect the public, the FAA and the 

application. The public and the FAA would be better served by freeing up limited FAA resources 

through the swift granting of this petition. The applicant is eager to start commercial operations 

supplementing transportation systems engineering research, benefitting the public.

(d) The petition has been filed in a timely manner.

As described more fully below, the requested exemption would permit the operation of small and 

relatively inexpensive unmanned aerial systems under controlled conditions in airspace that is limited, 

predetermined and provide an equivalent or better level of safety. Approval of this exemption would 

thereby fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “establish 

requirements for the safe operation of such aircraft systems in the national airspace system.” Section 

333(c) of the Reform Act. Thank you for your time and consideration to this petition for exemption.

Sincerely,

Dr. Luis Daniel Otero

Director of TSER Lab

Phone: 321-674-7173

Email: lotero@fit.edu

Department of Engineering Systems

Florida Institute of Technology

150 West University Boulevard

Melbourne, FL 32901

USA

Attachments:

DJI Phantom 2 Vision Plus User Manual -

http://dl.djicdn.com/downloads/phantom_2_vi

sion_plus/en/Phantom_2_Vision_Plus_User_M

anual_v1.8_en.pdf
7

DJI Inspire 1 User Manual -

http://dl.djicdn.com/downloads/inspire_1/en/I

nspire_1_Safety_Guidelines_and_Disclaimer_v1

.2_en.pdf

Appendix A: Exemption Requests and Equivalent Level of Safety

The Applicant requests an exemption from the following regulations pertinent to controlled and safe 

sUAS operations.

14 CFR PART 21, SUBPART H: AIRWORTHINESS CERTIFICATES 

Section 91.203(a)(1) requires all civil aircraft to have “an appropriate and current airworthiness 

certificate.” Part 21, Subpart H, entitled Airworthiness Certificates, establishes the applicability and the 

procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a)(1). 

With the size of the sUAS always being less than 55 lbs. and the limited flight operation areas, it is 

unnecessary to undergo the certificate of airworthiness process under Part 21 Subpart H to achieve or 

exceed current levels of safety, therefore meeting the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the 

Reform Act both authorize the FAA to exempt aircraft from the requirement of an airworthiness 

certificate of the sUAS involved upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas. 

These outlined conditions all apply to the UAS considered in this proposed exemption, therefore an 

airworthiness certificate is not applicable. 

See Exemptions: 11138, 11062, 11067, 11080, 11114, and 11112. 

14 CFR § 91.203 (A) & (B): CARRYING CIVIL AIRCRAFT CERTIFICATION AND REGISTRATION 

The regulation states: (a) “... no person may operate a civil aircraft unless it has ... an appropriate and 

current airworthiness certificate.” 

(b)”No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.” 

Due to the small size there is no open cabin or cockpit, there is no space, or onboard storage place 

located in/on the UAS in which to carry certification and registration documents. Furthermore, the sUAS 

will not carry a pilot, passengers nor flammable fuel and will operate only within small well-defined 

locations. All operations will be in compliance with the limitations and conditions stated in this 

application for petition. An equivalent level of safety will be achieved by keeping proper documentation 

at the location of the ground control station, read for access to all personnel. 

See exemptions: 9565A, 9565B, 9789, 9789A, 9797, and 9797A.

14 CFR § 91.7(A): CIVIL AIRCRAFT AIRWORTHINESS 

This regulation requires that “no person may operate a civil aircraft unless it is in airworthy condition.” 

Currently, no standard exists for airworthiness of the UAS. An equivalent level of safety will be achieved 

by ensuring compliance with the sUAS standard operating procedures, flight operations manuals, and 
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following established practices using safety checklists, pre-flight checklists and regularly scheduled 

maintenance. 

See similar exemptions: 11159, 11157, 11153, 11150, 11138, 11136, 11109 and 11080. 

14 CFR § 91.9 (B)(2): CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT 

The regulation provides guidance for aircraft flight manuals. (b)”No person may operate a U.S.-

registered civil aircraft ... (2) “For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 

of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any combination thereof.” 

Due to the small size, configuration with no cockpit or cabin for a pilot, passengers or crew, there is no 

room or capacity onboard to carry a flight manual. The equivalent level of safety will be achieved by 

keeping the flight manual(s) and standard operating procedures at the readily accessible at the Ground 

Control Station. Previous exemptions granted by the FAA concerning Section 91.9(b) establish that 

safety is not adversely affected when the approved Aircraft Flight Manual is kept at the Ground Control.

See exemptions: 8607, 8737, 8738, 9299, 9299A, 9564, 9564B, 9720, 10167, 10167A, 11112, 11114, and 

11138.

14 CFR § 45.23 & 91.9(C): MARKING OF THE AIRCRAFT 

Regulation 45.23 outlines (a) “Each operator of an aircraft must display on that aircraft marks consisting 

of the Roman capital letter “N” (denoting United States registration) followed by the registration number 

of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter.” 

(b) When marks include only the Roman capital letter “N” and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “lightsport,” “experimental,” or “provisional,” as applicable.” 

Regulation 91.9(c) states: “No person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with part 45 of this chapter.” 

The sUAS does not have entrance to a cabin, cockpit, or pilot station on which markings can be placed. 

The small size of the UAS prevents marking the UAS with two-inch lettering. Official marking systems for 

UAS have not yet been established for operations inside the NAS. 

The applicant is prepared to register all sUAS to be used in accordance with 14 CFR § 47 and have 

identification markings as large as practicable in pursuant to 14 CFR § 45 (c).

See exemptions: 10167, 10167A and 11112, 11136, 11109, and 11062. 

14 CFR § 61.113(A) & (B); 61.133(A): PRIVATE PILOT PRIVILEGES AND LIMITATIONS; PILOT IN 

COMMAND; COMMERCIAL PILOT PRIVILEGES AND LIMITATIONS 
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Sections 61.113 (a) & (b) outline the regulations for the limitation of private pilot privileges to noncommercial operations. Section 61.133(a) requires an individual to hold a commercial pilot’s license 

when acting as pilot in command of an aircraft used for compensation or hire. 

The sUAS will not carry a pilot nor passengers onboard. The proposed operations can achieve the 

equivalent level of safety by requiring the PIC to undergo sUAS flight training and hold at least a private 

pilot’s license, rather than a commercial pilot’s license to operate a sUAS. The sUAS has no one on board 

and does not present a need for a PIC with a commercial license. The area of operation is also vertically 

limited to 400ft AGL under VLOS conditions.

The FAA has issued the following exemptions to this regulation; see Exemption Nos. 11110, 11109, 

11062, 11065, 11067, 11136 and 11138. 

14 CFR § 91.103: PREFLIGHT ACTION 

This regulation describes that each pilot in command to take certain actions before flight to ensure the 

safety of the flight. As FAA approved flight manuals are not available for sUA sytems, an exemption is 

required.

To provide for an equivalent level of safety the following protocols will be in effect. The Pilot in 

Command and Ground Control Station crew will conduct pre-flight checks, weather updates, safety & 

flight planning and briefing, determining flight battery power requirements, data and landing/takeoff 

areas before commencing with flight operations. 

Summary of Pre-flight Checklist Items 

 Conduct visual inspection of entire airframe 

 Conduct visual inspections of fuselage, wings/rotor integrity 

 Battery power charge verification of all batteries including the sUAS, radio transmitter and other 

communication devices

 Verify that the altimeter is set to zero at UAS launch site/landing zones, check GPS altitude, 

location, compass heading/bearing 

 Verification of communication between PIC, VO(s) and/or GS crew before flight.

The failure of any portion of the pre-flight check will prevent take-off and will be noted in the flight log 

for inclusion within the regular maintenance schedule. 

14 CFR § 91.109(A): FLIGHT INSTRUCTION 

The regulation articulates that:

No person may operate a civil aircraft (except a manned free balloon) that is being used for 

flight instruction unless that aircraft has fully functioning dual controls.

Remotely piloted aircraft and sUAS, by design, do not have fully functional dual controls. Flight control is 

attained by the use of a control box that communicates directly with the aircraft via radio 

communications. Neither a pilot nor passengers will be carried in the aircraft and given the size and 

speed of the listed sUAS, an equivalent level of safety is achieved.
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The FAA has approved exemptions for flight training without fully functional dual controls for a number 

of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 11109, 11138, 11110. 

14 CFR § 91.119(C): MINIMUM SAFE ALTITUDES 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits 

aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. 

Because aerial survey, monitoring, mapping, inspection or data collection work for structural inspections 

must be accomplished at relatively low altitudes and at altitudes preferably less than 400 feet AGL, an 

exemption from Section 91.119(c) is requested. 

The equivalent level of safety will be achieved given the size, weight and speed of the sUAS. The small 

size, weight, and low speeds of the sUAS contribute to very minimal hazards to persons, property, 

vessels, vehicles or structures. The autopilot features include a preset prohibiting flights above 400ft 

AGL. Conventional aircraft cannot fly within the given parameters. The associated risks of the sUAS are 

marginal and are far less compared to manned flight operations at this altitude and speed.

The FAA has granted similar exemptions to others, including Exemptions: 4063, 11138, 11136, 11112, 

11110, 11109, 11080, 11066, 11063, 11062 and 11067. 

14 CFR § 91.121: ALTIMETER SETTINGS 

Section 91.121 prescribes that aircraft shall maintain cruising altitudes by reference to an altimeter that 

is set “... to the elevation of the departure airport or an appropriate altimeter setting available before 

departure.”

The listed sUAS will not have a barometric altimeter, rather a GPS altitude read out will be available and 

constantly monitored by the PIC and GCS. An equivalent level of safety is attained as the sUAS will never 

operate at higher than 400 feet AGL. Similarly, an equivalent level of safety is attained given the size, 

weight and speed of the sUAS as well as the strict location where it is operated.

Please note similar exemptions have been granted: 11153, 11150, 11138, 11136, 11159 and 11159. 

14 CFR § 91.151(A): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS 

This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed – (1) During the day, to fly after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes.” 

Applicant believes that an equivalent level of safety can be achieved by maintaining 20% of reserve 

battery. This criteria will be more than adequate to return the UAS to its planned landing zone from 

anywhere within the flight operations area. 

Operating the UAS, without 30 minutes of reserve fuel does not actualize the risks that Section 

91.151(a) was designed to alleviate. The UAS are constructed of lightweight materials, and have no 

onboard pilot, passenger(s), or cargo. The risk to human life and property is extremely minimal. Once 
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drained of power, the sUAS is designed to simply auto-land. An equivalent level of safety is exceeded 

given the comparison of the characteristics of conventional aircraft and a sUAS.

The FAA has granted similar exemptions in: 2689F, 5745, 10673, 10808, 11138, 11136, 11112, 10650, 

and 10159.

14 CFR § 91.405(A); 407(A)(1); 409(A)(2); 417(A): MAINTENANCE INSPECTIONS 

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...” 

Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an 

annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the owner 

or operator to keep records of maintenance work that has been accomplished by certificated 

mechanics, under Part 43, or licensed pilots and records of approval for aircraft return to service. 

This section is intended for aircraft with airworthiness certifications and does not apply. Therefore, an 

exemption is required. Pre-flight checks and regular sUAS inspection and maintenance will provide a 

similar level of safety. All inspection and maintenance procedures and results will be documented. Parts 

replaced shall be from the manufacturer themselves.

Similar exemptions have been granted including: 11159, 11157, 11150, 11153, 11138, 11136, 11109 and 

11080.